Finding 565388 (2023-001)

-
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2025-06-19

AI Summary

  • Core Issue: The organization failed to follow proper procurement methods for acquisitions over $250,000, leading to material noncompliance.
  • Impacted Requirements: Non-compliance with 2 CFR sections 200.318 through 200.326 regarding procurement standards for federal awards.
  • Recommended Follow-Up: Implement written policies and procedures to ensure adherence to procurement requirements and federal award terms.

Finding Text

Finding: 2023-001 Program Title: Congressionally Funded Community Projects Assistance Listing: 84.215K Contract Grant Number: S215K230172 Federal Award Years: July 1, 2023 to May 31, 2025 Federal Agency: U.S. Department of Education Type of Finding: Material Noncompliance Criteria: 2 CFR sections 200.318 through 200.326 establishes the procurement standards applicable to Non- Federal Entities applicable to federal awards. When acquisitions exceed the simplified acquisition threshold of $250,000, the non-federal entity must use one of the following procurement methods: the sealed bid method, the competitive proposals method, or the noncompetitive proposals method based on the criteria outlined in 2 CFR section 200.320. Condition: Based on procedures performed, SC&C identified acquisitions in excess of the simplified acquisition threshold that were not selected using an appropriate procurement method. Cause: The Organization was unaware of the compliance requirement. Also, the Organization did not follow its written procurement policy. Effect: $324,000 of costs are questioned costs as a result of failing to meet procurement requirements. This is considered material to the Congressionally Funded Community Projects. Repeat Finding: No Recommendation: We recommend the Organization establish and implement written policies and procedures to establish to ensure compliance with the compliance requirements and terms and conditions of the federal award. Views of Responsible Officials: Management agrees with the recommendations to establish and implement written policies and procedures to conform with the compliance requirements and terms and conditions of the federal award.

Corrective Action Plan

Response to the Schedule of Findings and Questioned Costs by Schriver Carmona, CPA on Audited Financial Statements of Beasley Brown Community Development Corporation for the Year Ended December 31, 2023 Finding #2023-001: BBCDC was unaware of the compliance requirement, and did not follow its written procurement policy, which resulted in $324,000 of questionable costs that caused it to not meet the procurement requirements for Congressionally Funded Community Projects. Action: At its Board of Directors meeting March 17, 2025, the Beasley Brown Community Development Corporation took the following action: It voted to revise its procurement policy to include a section entitled "Procurement Policy Procedures applicable to Non-Federal Entities.” This section will include all requirements stated in CFR 200.318 – 200.326. Procedures will require documented evidence of all proposed purchases and contracts under this section per CFR 200.318 – CFR 326 and approval by the Board of Directors or designated persons. The Board also moved that periodic training on CFR 200.318 – CFR 200.326 must be provided to the Board of Directors and other designated persons. Rev. Dr. Melvin Wilson, Jr., Chair – Board of Directors, will be responsible for ensuring the corrective action plan is implemented. The corrective action was implemented beginning March 18, 2025.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $934,199